Impartial Hearing Decision

FINDINGS OF FACT AND DECISION

Case Number: 262535

Student’s Name: STUDENT

School District: SCHOOL DISTRICT

Impartial Hearing Officer: Michele Host

Date of Filing: September 20, 2023

Hearing Requested by: PARENT

Time Sensitive: No

Dates of Hearing: December 5, 2023

Record Close Date: December 18, 2023

Date of Decision: December 19, 2023

NAMES AND TITLES OF PERSONS WHO APPEARED

DECEMBER 5, 2023:

For the Student:

REDACTED (Parents’ Counsel)

REDACTED (Mother)

For the District:

REDACTED (DOE Counsel)

INTRODUCTION AND PROCEDURAL HISTORY

This matter concerns the Student, a student classified as a student with a disability under the Individuals with Disabilities Education Act (“IDEA”). The Student’s eligibility for special education supports and services is not in dispute.

This matter comes before me on the Parents’ due process complaint, filed on or about September 20, 2023, concerning the 2023-2024 school year. In the Parents’ due process complaint, the Parents allege that the DOE failed to provide the Student with a free and appropriate public education (“FAPE”) for the 2023-2024 school year on multiple procedural and substantive grounds, including by failing to develop an Individualized Education Program (“IEP”) for the Student’s 2023-2024 school year. (P-A, p. 2) As relief, the Parents seek direct payment of the Student’s tuition at a private school (“Private School”) that has not been approved by the Commissioner of Education for the education of students with disabilities for the 2023-2024 school year.

I was appointed to this matter on October 5, 2023, and I held a pre-hearing conference on November 3, 2023, as well as a status conference on November 20, 2023. I scheduled an impartial hearing for December 5, 2023.

The impartial hearing took place on December 5, 2023. The DOE did not provide any documentary evidence; I entered the Parents’ exhibits A through J and L into evidence without objection.^[1] (Tr. 19-21) The DOE waived its opening argument, called no witnesses, conceded that it failed to meet Prong I of the Burlington-Carter test, and rested. (Tr. 19, 22, 28) Parents’ Counsel made an opening argument. (Tr. 22-24) The REDACTED Coordinator at the Private School provided a testimonial affidavit, which is in evidence as Parents’ Exhibit L, and the DOE did not cross-examine the REDACTED Coordinator. (Tr. 24) The Mother provided a statement originally marked for identification as Parents’ Exhibit K; the Mother then swore to the truth of her statement on the record and it was entered into evidence as Parents’ Exhibit K. (Tr. 25-27) The DOE did not cross-examine the Mother, and I asked one clarifying question of the Mother. (Tr. 24-25, 27) The Parents then rested. (Tr. 28) The DOE waived its closing argument and Parents’ Counsel rested on his opening argument. (Tr. 28-29)

The record in this case closed on December 18, 2023. A list of the documentary evidence in this proceeding is appended to this decision.

JURISDICTION

The due process hearing was held, and a decision in this matter is being rendered, pursuant to the Individuals with Disabilities Education Act (hereinafter, “IDEA”), 20 U.S.C. § 1400 et seq., and its implementing regulations, 34 C.F.R. § 300 et seq., and the New York State Education Law, Educ. Law Art 89 § 4404 et seq., and its implementing regulations, 8 N.Y.C.R.R. Part 200.

FINDINGS OF FACT

After considering all the evidence, as well as the argument of the Parents, my findings of fact are as follows:

A private neurological evaluation of the Student dated September 12, 2019, diagnosed the Student with a Language Disorder, moderate; a Specific Learning Disorder with Impairment in Reading (for word reading accuracy, reading rate and fluency), moderate; and a Specific Learning Disorder with Impairment in Mathematics (for fluency of calculation), severe. (P-D, p. 4) Among other recommendations, the evaluation recommended that the Student continue to be placed in a special school that allows for an individualized curriculum, with a very small studentteacher ratio and peers who also have learning disabilities and language disorders. (P-D, p. 5) The evaluation also recommended that the Student have at least twice weekly individual sessions with a learning specialist, and individual speech-language therapy (“SLT”) twice weekly. (Id., p. 5)

The Mother testified that the DOE last held an IEP meeting for the Student on September 12, 2022, and recommended general education with integrated co-teaching (“ICT”) services and SLT. (P-K, ¶ 27) At the time, the Mother expressed concerns to the IEP team about the recommended placement. (P-K, ¶ 27)

On July 7, 2023, the DOE provided the Student with a proposed public school placement. (P-K, ¶ 28) The Mother testified that she called and emailed the proposed public school’s Assistant Principal in charge of special education and did not hear back. (Id.) The Mother also left a message with the school’s parent coordinator. The Mother then emailed the DOE employee who sent her the placement notice, and that employee connected the Mother with the school’s principal and parent coordinator.

On July 31, 2023, the Mother spoke with an Assistant Principal from the Proposed Placement. (Id., ¶¶ 29-31) The Mother testified that the Assistant Principal told the Mother that: . . . she was not sure whether there would be available space in the ICT class, and she would not know until the first day of the school year. Moreover, she said that ICT was only available for core subjects and any electives (as a senior) that [the Student] would take would only have one teacher. She also indicated that the average class size for ICT is 34 kids, which is way too large for [the Student]. (P-K, ¶ 31)

On August 17, 2023, Parents’ Counsel sent the DOE a ten-day notice letter stating that the DOE had not developed an IEP for the Student’s 2023-2024 school year. (P-B) Parents’ Counsel wrote that the most recent IEP for the Student was dated September 12, 2022, and was not reasonably calculated to provide the Student with educational benefit. (P-B, p. 2) Parents’ Counsel further wrote that until the DOE recommended an appropriate placement for the Student, the Parents intended to enroll the Student at the Private School. (P-B, p. 5)

The Student is currently attending the Private School for the 2023-2024 school year. (PL, ¶ 11) The Private School is a private college preparatory school for grades six through twelve in REDACTED. (P-L, ¶ 5) The Private School features very small classes, with an average class size of between 10 and 12 students. (P-I, p. 1) The Student is enrolled in the Private School’s REDACTED program. The REDACTED Coordinator testified that “the REDACTED Program [at the Private School] is designed for students with learning disabilities. The Independent Transition Program (ITP) offers students a small study session once a day, and one weekly individual session with the Special Educator/Learning Specialist (REDACTED teacher) and the option to see a REDACTED teacher more often.” (P-L, ¶ 5)

The Parents signed an enrollment contract for the Student’s 2023-2024 school year with the Private School on February 8, 2023. (P-G) The Private School’s tuition for the 2023-2024 tuition is $77,859.00. (P-G) The Mother testified that the Parents are unable to afford the Student’s tuition, and the Private School agreed to defer payment until the conclusion of this case, although the Mother also testified that she understands the Parents are obligated to pay the Student’s tuition in full if the Parents do not prevail. (P-K, ¶ 24)

CONCLUSIONS OF LAW AND ANALYSIS

The IDEA establishes a “substantive right to a ‘free appropriate public education’” for children with disabilities. Endrew F. v. Douglas Co. School Dist, 137 S. Ct. 988, 993 (2017) (quoting Board of Ed. of Hendrick Hudson Central School Dist., Westchester Cty. v. Rowley, 458 U.S. 176 (1982)). The IDEA directs that, in general, an IHO’s decision must be made on substantive grounds based on a determination of whether the student received a FAPE. See 20 U.S.C. § 1415(f)(3)(E)(i). Under the IDEA and New York law, where there is a procedural violation resulting in a deprivation of educational benefits to a student or the student’s right to a free appropriate public education is significantly impeded, a hearing officer may find that a child did not receive a FAPE. See 20 U.S.C. § 1415 (f)(3)(E)(ii); 8 N.Y.C.R.R. § 200.5(j)(4)(ii).

A FAPE is offered to a student when: (a) the DOE complies with the procedural requirements set forth in the IDEA, and (b) the IEP developed by its CSE through the IDEA’s procedures is reasonably calculated to enable the student to receive educational benefits. Rowley, 458 U.S. at 206-07; Cerra v. Pawling Cent. Sch. Dist., 427 F.3d 186, 192 (2d Cir. 2005). “Not every procedural error will render an IEP legally inadequate.” M.H. v. New York City Dep’t of Educ., 685 F. 3d 217, 245 (2d Cir. 2012) (citation omitted). If a procedural violation is alleged, an administrative officer may find that a student did not receive a FAPE only if the procedural inadequacies (a) impeded the student’s right to a FAPE, (b) significantly impeded the parents’ opportunity to participate in the decision-making process regarding the provision of a FAPE to the student, or (c) caused a deprivation of educational benefits. 20 U.S.C. § 1415(f)(3)(E)(ii); 34 C.F.R. § 300.513(a)(2); Matrejek v. Brewster Cent. Sch. Dist., 471 F. Supp. 2d 415, 419 (S.D.N.Y. 2007).

In general, an impartial hearing officer's decision must be made on substantive grounds based on a determination of whether the student received a FAPE. 20 U.S.C. § 1415(f)(3)(E)(i). A school district offers a FAPE “by providing personalized instruction with sufficient support services to permit the child to benefit educationally from that instruction.” Rowley, 458 U.S. at 203. School districts are not required to “maximize” the potential of students with disabilities, but must provide “an IEP that is ‘likely to produce progress, not regression,’ and ... affords the student with an opportunity greater than mere ‘trivial advancement.’” Cerra, 427 F.3d at 195, quoting Walczak v. Florida Union Free Sch. Dist., 142 F.3d 119, 130 (2d Cir. 1998); see also Rowley, 458 U.S. at 199; Grim v. Rhinebeck Cent. Sch. Dist., 346 F.3d 377, 379 (2d Cir. 2003). The IEP must be “reasonably calculated to provide some ‘meaningful’ benefit.” Mrs. B. v. Milford Bd. of Educ., 103 F.3d 1114, 1120 (2d Cir. 1997); see Rowley, 458 U.S. at 192.

Throughout the hearing process, a school district bears the burden to show that it (1) complied with the IDEA’s procedural requirements; and (2) designed an IEP reasonably calculated to confer educational benefit on the student. C.B. ex rel W.B. v. N.Y. City Dep’t of Educ., 2005 U.S. Dist. LEXIS 15215, *37 (E.D.N.Y. June 10, 2005); 20 U.S.C. 1415(i)(2)(C)(iii); see also Walczak, 142 F.3d 119. However, “a parent or person in parental relation seeking tuition reimbursement for a unilateral parental placement shall have the burden of persuasion and burden of production on the appropriateness of such placement.” N.Y. Educ. § 4404(1)(c).

Under the three-prong test established by the Supreme Court in Sch. Comm. of Burlington, Mass, v. Dep’t of Educ. of Mass, 471 U.S. 359 (1985) and Florence County. Sch. Dist. Four v. Carter, 510 U.S. 7 (1993), parents who unilaterally place their children in private school are entitled to reimbursement from the school district if the services offered by the school district were inadequate or inappropriate, the services selected by the parent(s) were appropriate, and equitable considerations support the parent’s claim. See also Frank G. and Dianne G. v. Bd. of Educ. of Hyde Park, 459 F.3d 356 (2d Cir. 2006), cert. denied, Board of Educ. of Hyde Park Cent. School Dist. v. Frank G., 2007 U.S. LEXIS 11520 (Oct. 15, 2007). The first prong of the Burlington-Carter test encompasses whether the student’s IEP provided a FAPE. Brock v. Dutton, 2015 U.S. Dist. LEXIS 44254, *14 (S.D.N.Y. March 31, 2015).

The Parents have the burden of proving that the unilateral placement was appropriate. To meet this burden, the Parents must establish, by a preponderance of the evidence, that the unilateral placement provides “educational instruction specifically designed to meet the unique needs of a handicapped child.” Gagliardo v. Arlington Cent. Sch. Dist., 489 F.3d 105, 112 (2d. Cir. 2007) (quoting Frank G. v. Bd. of Educ., 459 F.3d at 364-65). The private school placement “need not meet the IDEA definition of a free and appropriate public education” or “state education standards or requirements.” Frank G. v. Bd. of Educ., 459 F.3d at 364.

The final prong of the Burlington-Carter test involves the balancing of the equities. 20 U.S.C. § 1412(a)(10)(C)(iii). Reimbursement may be limited or denied if the parents failed to act reasonably, did not cooperate with the DOE’s attempts to evaluate the student, or failed to provide proper notice of the parents’ rejection of the Student’s placement. See 20 U.S.C. § 1412(a)(10)(C)(iii). When considering whether the parents have shown that the equities weigh in the parents’ favor, it is important to consider “whether the [parents] cooperated with the district in its efforts to meet its obligations under the IDEA.” C.L v. Scarsdale Union Free Sch. Dist., 744 F.3d 826, 840 (2d Cir. 2014). Burlington-Carter Test Prong I

As to Prong I of the Burlington-Carter test, the DOE failed to meet its burden at hearing. The Supreme Court has found a reviewing court may expect school district staff “to be able to offer a cogent and responsive explanation for their decisions that shows the IEP is reasonably calculated to enable the child to make progress appropriate in light of his circumstances.” Endrew F. v. Douglas County School District, 137 S.Ct. 988, 1002 (2017). In this case, the DOE entered no documents into evidence, called no witnesses, and conceded that the DOE failed to meet its Prong I burden. (Tr. 19-20) Therefore, I cannot find that the DOE offered the Student a FAPE for the 2023-2024 school year. Burlington-Carter Test Prong II: The Appropriateness of the Parents’ Unilateral Placement

A unilateral private school placement must be reasonably calculated to enable the child to receive educational benefits, and must be likely to produce progress, not regression. The relevant standard to apply is whether “the unilateral private placement . . . provides educational instruction specifically designed to meet the unique needs of a handicapped child.” Gagliardo, 489 F.3d at 115 (quotations omitted). No single factor is dispositive in this analysis. Id. The private placement does not necessarily need to provide certified special education teachers or every special service that could assist in maximizing the Student’s potential. Bd. of Educ. of the Wappingers Cent. Sch. Dist. v. D.M., 2020 U.S. Dist. LEXIS 16007 (S.D.N.Y. 2020), aff’d 2020 U.S. App. LEXIS 39739 (2d Cir. 2020) (citation omitted). Moreover, parental placements are not subject to the same mainstreaming requirements as a school district placement. Frank G. v. Bd. of Educ., 459 F. 3d at 364.

In this case, the Parents submitted the neuropsychological evaluation of the Student, a June 12, 2023 academic report, the Student’s official transcript, the Student’s 2023-2024 enrollment contract and schedule, and an October 5, 2023 Teacher Report. (P-D; E; F; H) The Parents also submitted sworn testimony from the REDACTED Coordinator and the Mother. (PK; L)

The Student’s 2023-2024 schedule shows that the Student is enrolled in extremely challenging courses for the 2023-2024 school year, including four Advanced Placement courses. (P-F) The October 5, 2023 Teacher Report discusses the Student’s strengths and weaknesses and provides insight into how the Student works with the Student’s REDACTED Teacher on the Student’s assignments, as well as on the Student’s organization, time management, and study skills. (P-I)

The REDACTED Coordinator testified that although the Student is intelligent, the Student struggles with executive functioning, reading accuracy, reading comprehension, and writing. (P-L, ¶ 12) The REDACTED Coordinator testified in detail regarding the supports provided for the Student by the Private School, including checklists, templates, step-by-step directions, frequent teacher check-ins, scaffolding, and individual teacher attention. (P-L, ¶¶ 13-38) As discussed above, the Student also has one individual REDACTED session incorporated into the Student’s daily schedule throughout the week. (P-L, ¶ 40) The Student’s REDACTED instructor has a master’s degree in education. (Id., ¶ 43) The REDACTED Coordinator testified that “it is clear that [the Student] is progressing at [the Private School] this year, especially in terms of [the Student’s] planning and prioritizing [the Student’s] assignments, and planning work ahead of due dates.” (P-L, ¶ 45) The REDACTED Coordinator also noted that the Student’s written expression has improved. (Id.)

The Mother testified that at the Private School, the Student benefits from being placed in small classes with students with similar needs, as well as from the Private School’s individualized one-to-one support. (P-K, ¶ 13) The Mother further testified that the Student is provided with “graphic organizers and structured writing supports, in addition to repetition of concepts and opportunities for one-to-one instruction. [The Student] also benefits from the multisensory methods of instruction and accommodations, including the use of a computer, extended time on assignments, and preferential seating.” (P-K, ¶ 14) Regarding the Student’s grades thus far in the 2023-2024 school year, the Mother testified that the Mother has been “absolutely amazed” that the Student has “been able to keep up and do well in these highly challenging classes.” (Tr. 27)

As noted earlier, the DOE did not object to the Parents’ evidence being entered into the record, including the sworn affidavits of the Mother and the REDACTED Coordinator. There is nothing in the record that would undermine or controvert the testimony given by either witness. I therefore credit both witnesses’ testimony in full.

I find that the Parents have met their burden to prove that the private program offers an educational program that meets the Student’s needs under Prong II of the Burlington/Carter standard. The Private School has provided the Student with a truly individualized educational program, and when a teacher at a unilateral placement adapts instruction (for example, working one-on-one with the student, designing checklists and templates, providing graphic organizers and guided notes), these factors weigh in favor of the appropriateness of the parents’ unilateral placement. Frank G., 459 F.3d at 365-66. Here, the weight of the evidence establishes that the Student’s individual special education needs are being addressed by the Private School and that the instruction offered is “reasonably calculated to enable the child to receive educational benefits.” Frank G., 459 F.3d at 364. Burlington-Carter Test Prong III: Equitable Factors

Equitable factors are relevant to fashioning relief under the IDEA. Burlington, 471 U.S. at 374; C.L. v. Scarsdale Union Free Sch. Dist., 744 F.3d 826 (2d Cir., 2014); M.C. v. Voluntown Bd. of Educ., 226 F.3d 60, 68 (2d Cir. 2000) (citations omitted); see also Carter, 510 U.S. at 16 (“Courts fashioning discretionary equitable relief under IDEA must consider all relevant factors, including the appropriate and reasonable level of reimbursement that should be required. Total reimbursement will not be appropriate if the court determines that the cost of the private education was unreasonable”). Reimbursement of private school tuition may be reduced or denied when parents fail to challenge the appropriateness of an IEP in a timely manner, fail to make their child available for evaluation by the district, or upon a finding of unreasonableness with respect to the actions taken by the parents. 20 U.S.C. § 1412(a)(10)(C)(iii); 34 C.F.R. § 300.148(d); see S.W. v. New York City Dep’t of Educ., 646 F. Supp. 2d 346, 362-64 (S.D.N.Y. 2009); Thies v. New York City Bd. of Educ., 2008 U.S. Dist. LEXIS 11354 (S.D.N.Y. Feb. 4, 2008); Werner v. Clarkstown Cent. Sch. Dist., 363 F. Supp. 2d 656, 660-61 (S.D.N.Y. 2005).

The IDEA allows that reimbursement may be reduced or denied if parents do not provide notice of the unilateral placement either at the most recent CSE meeting prior to removing the student from public school, or by written notice ten business days before such removal, “that they were rejecting the placement proposed by the public agency to provide [FAPE] to their child, including stating their concerns and their intent to enroll their child in a private school at public expense.” 20 U.S.C. § 1412(a)(10)(C)(iii)(I); see 34 C.F.R. § 300.148(d)(1). This statutory requirement “serves the important purpose of giving the school system an opportunity, before the child is removed, to assemble a team, evaluate the child, devise an appropriate plan, and determine whether a [FAPE] can be provided in the public schools.” Greenland Sch. Dist. v. Amy N., 358 F.3d 150, 160 (1st Cir. 2004).

In this case, the record does not establish that the Parents “acted with the requisite level of unreasonableness or misconduct that reimbursement should be denied on equitable grounds.” Jennifer D. ex rel. Travis D. v. New York City Dept. of Educ., 550 F. Supp 2d 420, 437 (S.D.N.Y. 2008). There is nothing in the hearing record to suggest, let alone demonstrate, that the Parents interfered in any manner with the CSE’s evaluation of the Student or prevented it from providing the Student with a FAPE for the 2023-2024 school year. Furthermore, the DOE has raised no argument that the equities would not weigh in favor of the Parents. The record supports a finding that the Parents cooperated fully with the DOE and timely sent the requisite ten-day notice to the DOE in advance of the commencement of the 2023-2024 school year.

In addition, the record clearly establishes that the Parents incurred an obligation to pay the Private School the aggregate tuition sum of $77,859.00. (P-G; K, ¶ 24) Given my finding that the Private School is the appropriate placement for the Student, the Student is entitled to an award for direct payment for the Student’s tuition at the Private School for the 2023-2024 school year, to be paid directly to the Private School. See E.M. v. New York City Dep’t of Educ., 758 F.3d 442, 453-54 (2d Cir. 2013) (“direct payment fits comfortably within the Burlington-Carter framework: like reimbursement, direct payment to the private school that provided the required educational program ‘merely requires [the school district] to belatedly pay expenses that it should have paid all along and would have borne in the first instance had it developed a proper IEP.’”) (quoting Burlington, 471 U.S. at 370-71). Direct tuition funding is relief encompassed by the equitable remedial powers inherent in the IDEA. See, e.g., Mr. and Mrs. A. v. New York City Dep’t of Educ., 769 F. Supp. 2d 403, 406 (S.D.N.Y. 2011).

While the amount of tuition at the Private School is not insignificant, I do not find that the tuition costs are excessive or unreasonable, given the Private School’s educational program for the Student. Carter, 510 U.S. 7, 15-16. After considering the entire record presented at hearing, I find that the equities support the Parents’ claim for direct payment.

OTHER RELIEF SOUGHT

In addition to direct payment of the Student’s tuition at the Private School, the Parents seek additional relief that I will discuss below. Attorneys’ Fees

The Parents also requested attorneys’ fees and expenses in the Parents’ due process complaint. (P-A, p. 5) The IDEA does not authorize an administrative officer to award attorneys’ fees or other costs to a prevailing party, and entitlement, if any, to costs must be determined by a court of competent jurisdiction. 20 U.S.C. § 1415(i)(3)(B); Murphy v. Arlington Cent. Sch. Dist. Bd. of Educ., 402 F.3d 332 (2d Cir. 2005); see also Application of a Student with a Disability, Appeal No. 08-008 (March 31, 2008); Application of a Child with a Disability, Appeal No. 06-109 (Oct. 27, 2006). Only a court can determine if a party is entitled to attorneys’ fees and I would be exceeding the scope of my authority by determining that the Parents are the prevailing party entitled to costs. Therefore, to the extent that the Parents are seeking reimbursement and/or payment of attorneys’ fees and costs, the Parents’ request is denied.

I have reviewed the parties’ remaining contentions and find them to be either unnecessary to this decision, without merit, beyond my jurisdiction, or without sufficient basis in the record for a finding. Accordingly, any relief not specifically discussed in this decision is denied, and all the Parents’ remaining claims not discussed herein are dismissed with prejudice.

ORDER

Based above the above findings of fact, it is hereby:

1. ORDERED, that the DOE shall directly fund the Student’s 2023-2024 tuition at the Private School in the amount of $77,859.00, within 35 days of receipt of appropriate invoices.

SO ORDERED.

DATED: December 19, 2023

Michele Host (signed electronically)

Impartial Hearing Officer

Michele Host

NOTICE OF RIGHT TO APPEAL

Within 40 days of the date of this decision, the parent and/or the Public School District has a right to appeal the decision to a State Review Officer (SRO) of the New York State Education Department under section 4404 of the Education Law and the Individuals with Disabilities Education Act.

If either party plans to appeal the decision, a notice of intention to seek review shall be personally served upon the opposing party no later than 25 days after the date of the decision sought to be reviewed.

An appealing party’s request for review shall be personally served upon the opposing party within 40 days from the date of the decision sought to be reviewed. An appealing party shall file the notice of intention to seek review, notice of request for review, request for review, and proof of service with the Office of State Review of the State Education Department within two days after service of the request for review is complete. The rules of procedure for appeals before an SRO are found in Part 279 of the Regulations of the Commissioner of Education. A copy of the rules in Part 279 and model forms are available at: http://www.sro.nysed.gov.

APPENDIX A – ADMITTED EXHIBITS

DISTRICT’S EVIDENCE

None

A. PARENTS’ EVIDENCE Impartial Hearing Request 9/20/2023 5 pages

B. Ten-Day Notice 8/17/2023 5 pages

C. Response to Ten-Day Notice 8/28/2023 1 page

D. Neuropsychological Evaluation 9/12/2019 29 pages

E. Academic Report 6/12/2023 1 page

F. Official Student Transcript Undated 1 page

G. Enrollment Contract 2/8/2023 4 pages

H. Student Schedule 2023-2024 1 page

I. Teacher Report 10/5/2023 8 pages

J. Email Exchange 7/7/23-7/21/23 2 pages

K. Statement in Lieu of Direct Testimony – Mother 11/29/2023 4 pages

L. Affidavit in lieu of Direct Testimony – REDACTED Coordinator IMPARTIAL HEARING OFFICER’S EVIDENCE NONE 11/27/2023 10 pages

Footnotes

[1] The Parents’ exhibits are cited as “P” followed by a letter, and the transcript is cited by “Tr.” followed by a page number.